KOZ Investment (“KOZ”, “we”, “us”) respects your privacy. This policy explains what personal data we collect through kozinvestment.com (the “Website”) and our consultancy services, why we process it, and the rights you have under Turkish law — principally Law No. 6698 on the Protection of Personal Data (“KVKK”), as amended in March 2024, the Electronic Commerce Law No. 6563, and the Law on Electronic Communications No. 5809.
1. Data Controller
The data controller (“veri sorumlusu”) under Article 3 of the KVKK is:
KOZ Investment
Şirinevler Mahallesi, Mareşal Fevzi Çakmak 2. Sokak No 9/B, Bahçelievler, İstanbul
Email: info@kozinvestment.com
Phone: +90 541 946 40 88
We are registered with the Turkish Data Controllers’ Registry (VERBİS) where such registration is required.
2. Personal Data We Collect
We only collect the data we need to answer your enquiry, deliver our services, and comply with the law. Depending on how you interact with us, we may process:
- —Identity & contact data: first name, last name, nationality, country of residence, email, telephone number.
- —Enquiry data: property interest, budget range, intended use, citizenship goals, and the content of messages you send us.
- —Transaction & KYC data (only if you become a client): passport copy, proof of address, source-of-funds evidence, tax identification number, and documents required under anti-money-laundering legislation (Law No. 5549).
- —Technical data: IP address, browser and device information, pages visited, referrer, and cookie identifiers — see Section 7.
- —Marketing data: newsletter subscription status and your communication preferences.
We do not intentionally collect special categories of personal data (Article 6 KVKK). Please do not send us such data unless we specifically request it in writing.
3. Purposes & Legal Basis
We process your personal data for the following purposes, on the legal bases listed below (Article 5 KVKK):
| Purpose | Legal Basis (KVKK Art. 5) |
|---|---|
| Responding to enquiries and consultation requests | Necessary for the conclusion or performance of a contract (Art. 5/2-c) |
| Delivering property search, citizenship advisory and related services | Performance of a contract (Art. 5/2-c); legitimate interest (Art. 5/2-f) |
| Identity verification, anti-money-laundering, tax and accounting records | Legal obligation (Art. 5/2-a & ç) |
| Newsletters and marketing communications | Your explicit consent (Art. 5/1) — withdrawable at any time |
| Website security, fraud prevention and analytics | Legitimate interest (Art. 5/2-f) |
5. Retention
We retain personal data only for as long as necessary for the purposes described above, and thereafter for the periods required by Turkish law:
- —Enquiry and marketing data: up to 3 years from your last interaction;
- —Client and transaction records: 10 years (Turkish Code of Obligations No. 6098, Art. 146);
- —Accounting records: 10 years (Tax Procedure Law No. 213; Turkish Commercial Code No. 6102);
- —Website logs: up to 2 years (Law No. 5651).
When retention periods expire, data is deleted, destroyed or anonymised in line with our Personal Data Retention and Destruction Policy.
6. Security Measures
We apply technical and administrative measures appropriate to the risk, including access controls, encryption in transit (TLS), secure backups, confidentiality undertakings from staff and processors, and periodic reviews — consistent with Article 12 of the KVKK and guidance of the Turkish Personal Data Protection Authority (KVKK Kurumu).
8. Your Rights
Under Article 11 of the KVKK, you have the right to:
- —Learn whether we process your personal data and, if so, request information about it;
- —Know the purpose of processing and whether data is used for that purpose;
- —Know the third parties to whom data is transferred in Turkey or abroad;
- —Request correction of incomplete or inaccurate data;
- —Request deletion or destruction of data under the conditions set out in Article 7;
- —Object to outcomes produced solely by automated processing;
- —Claim compensation for damage arising from unlawful processing.
To exercise these rights, submit a written request in line with the Communiqué on Application Procedures to the Data Controller to the address in Section 1, or by email to info@kozinvestment.com. We will respond free of charge within 30 days. If you are not satisfied, you may lodge a complaint with the Turkish Personal Data Protection Authority at kvkk.gov.tr.
9. Children
The Website and our services are directed at adults. We do not knowingly collect personal data from persons under 18. If you believe a minor has provided us data, please contact us and we will delete it.
10. Changes to This Policy
We may update this policy from time to time to reflect changes in law or in our practices. The “Last updated” date at the top of this page will always show the current version. Material changes will be communicated on the Website or by email where you have subscribed.
11. Contact
For any question regarding this policy or your personal data, please write to:
KOZ Investment — Data Protection
Şirinevler Mahallesi, Mareşal Fevzi Çakmak 2. Sokak No 9/B, Bahçelievler, İstanbul
Email: info@kozinvestment.com
Phone: +90 541 946 40 88
In case of any inconsistency between the English and Turkish versions of this policy, the Turkish version shall prevail for the purposes of Turkish law.